Rule 192.6 of the Texas Rules of Civil Procedure states:
(a) Motion. A person from whom discovery is sought, and any other person affected by the discovery request, may move within the time permitted for response to the discovery request for an order protecting that person from the discovery sought. A person should not move for protection when an objection to written discovery or an assertion of privilege is appropriate, but a motion does not waive the objection or assertion of privilege. If a person seeks protection regarding the time or place of discovery, the person must state a reasonable time
and place for discovery with which the person will comply. A person must comply with a request to the extent protection is not sought unless it is unreasonable under the circumstances to do so before obtaining a ruling on the motion.
(b) Order. To protect the movant from undue burden, unnecessary expense, harassment, annoyance, or invasion of personal, constitutional, or property rights, the court may make any order in the interest of justice and may - among other things - order that:
(1) the requested discovery not be sought in whole or in part;
(2) the extent or subject matter of discovery be limited;
(3) the discovery not be undertaken at the time or place specified;
(4) the discovery be undertaken only by such method or upon such terms and conditions or at the time and place directed by the court;
(5) the results of discovery be sealed or otherwise protected, subject to the provisions of Rule 76a.
College Station, Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice An Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal document commonly used in College Station, Texas. This affidavit is filed to request a change in the designated place for a deposition, which may be necessary due to various reasons such as convenience, accessibility, or logistical issues. The purpose of this affidavit is to present strong and valid reasons to the court, supporting the motion for a change in the deposition location. By providing detailed information, relevant facts, and persuasive arguments, the affine aims to convince the court that the designated place for the deposition should be altered to ensure fairness, efficiency, and convenience for all parties involved. The exact content and format of the affidavit may vary depending on the circumstances and requirements of the case. However, it typically includes the following key elements: 1. Heading: The affidavit begins with the title "Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice." This heading clearly indicates the purpose of the document. 2. Introduction and Identification: The affine introduces themselves, providing their full name, address, contact information, and their role or relationship to the case (e.g., party, attorney, witness). It is crucial to establish credibility and establish why the affine's submission is relevant to the matter at hand. 3. Background and Context: This section provides a concise overview of the case, outlining the relevant facts and events leading to the current deposition dispute. It should explain why changing the deposition location is necessary, emphasizing any hardships or inconveniences caused by the original designation. 4. Reasoning and Arguments: Here, the affine presents a clear and logical argument as to why the change in deposition location is appropriate and justified. This section should include strong legal or practical reasons, such as the unavailability of essential witnesses or evidence at the original location, the need to accommodate a disabled party, or the excessive travel costs or time required for one or more parties involved. 5. Supporting Evidence: The affine may attach supporting documentation, such as witness statements, expert opinions, medical records, or travel expense estimates, to strengthen their case and demonstrate the validity of the arguments presented. 6. Conclusion and Prayer for Relief: In the final section, the affine summarizes their main points and reiterates the desired relief sought — the court's order granting the motion for a change in the deposition location. The affine should include their signature, the date of signing, and a notarial statement attesting to the truthfulness of the contents. Different types of College Station Texas Affidavits in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice may exist depending on the specific nature of the motion. For example, there could be separate affidavits filed by different parties involved in the case, such as the plaintiff, defendant, or an expert witness. Each affidavit may contain unique facts, arguments, and supporting evidence tailored to the individual circumstances.
